Appendix A: McKeel critique of Allen2 January 2012 GSI white paper

Uranium NDT Hours at GSI; Cost Allocations by Year According to
Purchase Orders Listed in TBD-6000 Appendix BB Rey 0 dated 6/25/07
-Data from ~ to Dan McKeel (e-mail dated 1-18-09)

E-mail subject line: Fwd: "Right from NIOSH's Report" URANIUM AT GSI

Body of e-mail message:
Begin forwarded message:

From:

Date: January 18, 2009 10:11:08 AM CST

To: Dan McKeel <danmckeel2@aol.com>

Ce; ’ -

Subject: "Right from NIOSH's Report", then they ignore this most important fact, Re: The
Badges for 1964-66 !

Re:

Thank you for all of the recent info from Dow and GSI. Please send me the proof that shows 400
hrs of AEC uranium work at GSI in 1962 compared with only 28 hrs in 1964, the year LJE says
was the peak. This is most important to get in the record ASAP as clearly as possible to refute
NIOSH's attempt to use 1964 badge data to bound the entire 1953-1966 AEC period at GSI.
Thanks! --Dan 1/18/09

As requested !
Effective Date: 6/25/2007 Revision No. 0 Page 2 of 12 (below) "Right from NIOSH's Report",
then they ignore this most important fact !

Office of Compensation Analysis and
Document Number: Battelle-TBD-6000
Support Appendix BB

Effective Date: 6/25/2007 Revision No. 0 Page 2 of 12

General Steel Industries, Inc., at the same address. The ingots were in the form of
cylinders 18 to 20 inches in diameter, approximately 18 inches long, and weighing up to
3000 pounds, The betatron x-ray equipment was Government owned. The uranium to be
x-rayed was owned by the AEC and provided by Mallinckrodt3,

BB.2.2 Frequency of uranium X-rays
General Steel Industries work with uranium was performed under purchase orders with
Mallinckrodt Chemical Works starting in March of 1958. These purchases orders cover

the time period March 1, 1958 through June 30, 19664, These purchase orders indicate
that the work was to “X-ray material as requested by Mallinckrodt...". They also


McKeel critique of David Allen and NIOSH January 2012 white paper
to as the “railroad” position. In this position, the equipment is assumed to be on a railroad
type cart located in the shooting room. For this configuration, the betatron is assumed to

scenarios could involve aiming the betatron head 45 degrees to the right and to the left of
that position.

It should be noted that aiming 45 degrees to the right would be a “flipped

head” position.

. Comment:

"It should be noted that aiming 45 degreas to the right would be a “flipped

This is “totally incorrect”!_ NO FLIPPING IS NEEDED.

Please note this very clear Allis-Chalmers Betatron PROMOTIONAL PHOTO:

Allis-Chalmers promotional literature states that 45 degree rotation of the camera head in
cither direction is a normal feature of their Betatron. See the large casting on a flatbed RR car
image on page 14, for example. The Betatron head would have to be rotated 45 degrees in either
direction to image the entire casting using x-ray NDT. The downside is that a shot using this
scenario to the right would send the beam down the long “L” tunnel that contains the railroad
tracks, The thin unshielded roll up ribbon door that closed the Old and New Betatron building
tunnels in the covered period would not have stopped the Betatron beam in this position.

Head-flipping is quite different—cited as being dangerous —and is forbidden as a safe
operational technique to x-ray inspect objects in the opposite direction from the limited normal
movements of the Betatron head. Head flipping has been well described by GSI Betatron
workers. It is troubling that normal and banned operations are being confused at this late stage of

the dose reconstruction program when 94% of GSI dose reconstructions have been completed.

-3%


Appendix B: McKeel critique of Allen2 January 2012 GSI white paper

IM 5 87 PP he SAP? NOD |

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Begin forwarded message:
From: '
Date: June 26, 2009 3:20:42 PM CDT
To: "
Subject: Re: Distance information.
-I CONTACTED . AND AS THE CROW

FLYS, WE ESTIMATE THE DISTANCE FROM THE NEW BETATRON TO THE OLD
BETATRON AT AROUND 300 FEET-----

From: . .

Date: 6/26/2009 2:05:37 PM
To:

Cc: Dan McKeel

Subject: Distance information.


McKeel critique of David Allen and NIOSH January 2012 white paper

numbers. The preponderance of worker testimony evidence is that most of the AEC MCW
uranium NDT work was performed during the entire covered period was done in the New
Betatron building, not the New Betatron building as Mr. Allen indicates, It is true that overall
Betatron activity likely increased with the addition of the second unit from Eddystone in 1963.
However, I would point out again, that NIOSH has zero shot records or log books or shipping
manifest, or steel materials inventory records, that would prove this is the case, The written
records of GSI operations during the covered period are practically nonexistent. So, Mr. Allen's
“facts” are mostly educated suppositions (guesses) and are definitely not established facts.

D. Issue #4: David Allen has mischaracterized the Betatron NDT work on MCW
uranium products in other significant ways in the January 2012 white paper.

a) Workers testify that a large majority of the GSI NDT examinations of MCW uranium
took place in the Old Betatron building. That must be the case, because the New Betatron
machine and building were not in place at GSI until 1963, Nevertheless, Mr. Allen implies that
the model to be used for uranium doses at GSI should be based on exposures in the New
Betatron building. This analysis is therefore by definition false and misleading, and the
underlying assumption that both Betatrons and their facilities are equivalent is incorrect. Based
on OCAS-IG-003 dose from all radiation source terms at a facility during the covered period
must be determined. Such is not the case for GSI in any NIOSH technical report, including David
Allen's January 2012 white paper under discussion here.

b) Mr, Allen fails to note that no MCW-AEC purchase orders to GSI for NDT
examinations are available for the years 1953-1968 of the covered period,

c) During the DOE cleanup of the GSI Betatron facilities in 1992, ORNL found residual
uranium contamination only in the Old Betatron Building. Mr. Allen's January 2012 white paper
ignores this well documented fact.

E. Issue #5: Very limited, non-representative film badge data from 89 men doing a
single job (Betatron operator/radiographer) of a workforce of 3000 to 4000 men and
women for 3/13ths of the covered period in years is in no way representative of the entire
work force. As such it cannot be used to bound doses for anyone except the 89 persons with
data. With respect to the rest of the GSI workforce, there is absolutely no film badge or urine
bioassay for uranium data, or ambient air or “dust study" data for any portion of the covered
period.

Petitioners contend there is no compelling scientific rationale for being able to back
extrapolate the film badge data to other workers and to the first ten years of the covered period,
Petitioners further challenge the validity of NIOSH accepting SC&A evidence from Landauer
that the highest film badge readings at GSI were retracted, Such retractions of GSI film badge

data were not brought up by Landauer representatives and first
discussed the GSI film badge data with McKeel in 2006 thirteen months before either NIOSH or
SC&A were even aware of the existence of this information. In fact, Ms. went out of her

way to highlight the highest reading of 30 REM, and to point out that this was received in one
quarter, That quarter coincided with a high exposure accidental exposure known to have
occurred with this individual ( ) as supported by detailed affidavits from coworkers who
were eye witnesses to these events. There is evidence that the GSI film badge “retraction” letter
signatures by individuals with the highest FB readings were forged by GSI supervisors. NIOSH
has refused to supply petitioners with copies of the unredacted letters citing the Privacy Act of

24s


Appendix A: McKeel critique of Allen2 January 2012 GSI white paper

contained “Betatron labor charges, including operation and maintenance and all overhead
shall be billed at $16.00 per hour.” The last purchase order covering the period of July 1,
1965 to June 30, 1966 indicated a billing rate of $35.00 per hour. The purchase orders
also indicated that the work was not to exceed a set cost. The first purchase order,
covering the period March 1, 1958 to June 30, 1958 stipulated a monthly limit of $500,
That purchase order was extended to October 31, 1958 and added $1800 to the total limit
(an additional $450 per month), A new purchase order covered the period November I,
1958 to June 30, 1959 and stipulated a monthly limit of $450 and a total limit of $3600
(equal to $450 per month). ‘The next purchase order covered July 1, 1959 to June 30, 1960
and stipulated a monthly limit of $450 with a total limit of $7200. It should be noted that
the total limit does not add up to 12 months at the monthly limit. This is the only purchase
order with this conflict. Since these are limits and not estimates, the most limiting of the
two values will be used in this appendix which is consistent with purchase orders written
both before and after this one.

From that point on, the purchases orders were written annually covering a period of July |
to June 30 of the next year. All but the last order stipulated a billing rate of $16 per hour.
The purchase order starting in 1960 stipulated no total limit. Only a monthly limit of $450
per month was specified, After that, only a total limit was specified. These limits were
$7000 for the purchase order starting in 1961, $2000 for the purchase order starting in
1962, and $450 for each of the remaining purchase orders.

From this information, it is possible to determine the maximum hours per year that
General Steel Industries spent on operations, maintenance and overhead associated with x-
raying uranium for Mallinckrodt Chemical Works. Through June 30, 1961 the limit was
generally $450 per month at $16 per hour or 337.5 hrs per year. The remaining years are
shown below.

July 1, 1961 to June 30, 1962 437.5 hrs/yr (based on a total limit of $7000)

July 1, 1962 to June 30, 1963 125 hrs/yr (based on a total limit of $2000)

July 1, 1963 to June 30, 1965 28 hrs/yr (based on a total limit of $450)

July 1, 1965 to June 30, 1966 13 hrs/yr (based on a total limit of $450 at $35/hr)

These estimated hours are considered the maximum hours that could have been spent x-
raying uranium. These are considered maximum because the purchase orders set these

costs as a limit. There is no indication how much of the available funds were actually

Ramspott: How can using Radiation badge information from 1964- 1966, if I understand
correctly, be accurate if NIOSH/ Appendix BB. says:

" These estimated hours are considered the maximum hours that could have been spent x-raying
uranium".

"Directly from"; Appendix BB.2.2


Daniel W. McKeel, Jr., M.D. Public Comment
February 28, 2012 ABRWH Meeting

Good afternoon to the Board,

I am speaking as the co-petitioner for General Steel Industries
SEC-105 being handled by the TBD-6000 work group. Some striking new
information has emerged that I need to share with the Board.

The findings I am reporting today emerged from a careful scrutiny
of the NRC FOIA 2010-0012 material I first brought to the attention of
the Board and NIOSH in December 2010. NRC later posted these 1,016
pages of AEC cobalt-60 by-product materials licensing information to
GSI on their public website, The new findings also were verified and
supported by re-interviewing a number of GSI former workers, who
substantially corroborated the findings I am about to discuss.

FINDING #1. The Betatron exit tunnel doors were NOT double leaf
and lead shielded during the covered period of 1953-1966 as is stated
in the January 2012 Betatron Allen white paper. We have photographic
and affidavit proof that the double leaf doors were installed in 1968
after the covered period at GSI had ended.

Betatron workers to a man had always stated that the tunnel exit
doors on both the Old and New Betatron buildings during 1963-66 were a
“steel red ribbon roll up door.”

NIOSH evidence: The 30 page January 2012 Allen white paper shows
drawings of the New Betatron buildings from the GSI cobalt-60 AEC 1968
and 1971 license renewal applications. Again, 1968 was two years after
the covered period had ended. The text noted the doors were “double
leaf with lead shielding." Similar “double leaf doors" were described
and shown in drawings in the ORNL DOE cleanup report for the GSI New
Betatron building in 1992. According to ORNL, the Old Betatron tunnel
had only a double leaf door (no lead shielding).

McKeel~ evidence: There is both old and recent direct
worker confirmation that in the covered time period the Old and New
Betatron tunnel exits were closed off by “red, steel, roll up ribbon
doors” that could not be retrofitted with lead shielding.

a3 =


Appendix B: McKeel critique of Allen2 January 2012 GSI white paper

Appendix B; Nearest Building to Betatrons Analysis to Correct Data Presented
in GSI Betatron Operations White Paper dated January 2012

Subject line; Fwd: Betatron Distance information.
E-mail date: Sat. Feb. 25, 2012 10:10 AM

FYL:
SC&A actually noted 76 meters.

GSI appears to have lied on their Application!
Subject: Fwd: Distance information,

From: t :

Date: June 27, 2009 5:42:46 PM CDT

To: Dan McKeel <danmckeel2@aol.com>
Subject: Fwd: Distance information.

Dan;

asked _ to contact some of the Betatron workers to get their estimation of the distance from
Old and New Betatron Buildings.

_ sent me their reply (see below)

I wanted to double check my own estimation using my "ruler and meter to feet calculations"
formula.

(This was also based on SC&A's distance calculations)
Results;
Workers- 300 feet.
312 feet (aprox. 95m x 3.28 ft. = 311.6 feet )

We “all" pretty much agreed .
My drawing etc. was actually pretty accurate !

[JWR Betatron drawing & measurements inserted here}


McKee! critique of David Allen and NIOSH January 2012 white paper

and x-rays that were prevalent during Betatron shots. Photos of these thin metal doors have been
provided previously to NIOSH, the Board and SC&A by Mr, _ and the petitioners.

10, Although the reasoning is obtuse and poorly described, using tortured scientific logic
in my opinion, Mr. Allen improperly attempts to “explain away” direct
measurement of residual Betatron activity for 15 minutes after the camera is turned off. The
petitioners have produced several papers (many more being available) that clearly show that
many internal components of all high energy particle accelerators become ectivated with
prolonged duty cycles, and that some of these activation products have half lives longer than
15 minutes. To the petitioners, therefore, the ' observation is both expected and readily
explainable. The appearance is that NIOSH wishes to explain away the residual radioactivity
because it is “inconvenient” and results in a higher overall dose to Betatron operators, Good
science and the intent of Congress was that workers should be compensated and that such
adversarial tactics have no valid place in implementing the dose reconstruction program under
EEOICPA 2000,

11, After spending 16 months developing new dose reconstruction models and methods
for ascertaining external and internal doses to all GSI workers, the two main work products that
NIOSH has produced, the October 2010 and January 2012 David Allen white papers, are full of
bad assumptions, use data from the residual period that cannot apply to the covered period, and
incorrectly mode] Betatron doses and x-ray particle accelerators that produce a very tight,
narrow, and highly directional beam that has to be widened through a beam flattener (read
spreader), by using as a source a Cobalt-60 gamma source beam that is not collimated and
radiates as a sphere in all directions. NIOSH has claimed an 80 Ci C-60 source was not at GSI
during the covered period 1953-66; GSI workers have claimed otherwise.

The overall result of these new studies and new dose modeling results is a predictable
lowering of the overall dose attributed to Betatron operators and assistant operators. By
incorrectly assuming the presence of lead (Betatron tunnel exit doors) and steel and concrete
shielding (inside steel plates, outside extra concrete added to walls of the 6 building Radiography
facility) that was not there during the covered period when radium-226 was being employed,
NIOSH has lowered the dose that will be assigned to workers. Further, dose lowering has been
achieved by more rather than less reliance on film badge data that, in the petitioner's view, have
been manipulated and mishandled by both NIOSH and SC&A. Vital information about the

eft


MeKeel critique of David Allen and NIOSH January 2012 white paper

Legend. A red ribbon door in GSI building 10 blocks the entry to the
New Betatron break area and tunnel in 2006. This type of door is
identical to the “red, steel roll up ribbon doors” that numerous GSI
workers testify was present at the ends of the GSI Betatron building
railroad track tunnels during the 1963-66 covered period. Photo by
Dan McKeel, GSI SEC-00105 co-petitioner on site visit 9-26-2006.

H. Issue 9. Alteration of the original NRC FOTA 2010-0012 drawing of the 1962 status

of the inner Radiography structure in GSI building 6. McKeel’s comments on 2/28/12 to the
full Board were as follows:

Finding #2. The building 6 radiography facility has
been incorrectly modeled for the period 1953-1962 when
Radium-226 was being used for nondestructive testing.
This is an SEC issue. In the October 2011 first Allen
GSI white paper on portable sources, on page X is
shown an August 1962 drawing of the building six
roofless radiography facility. SC&A uses the same
drawing in their review. Packet 3 of 37 of the NRC
FOIA 2010-0012 material that Dan McKeel obtained, on
page X, shows the same drawing in which ”D. Darr” has
signed the drawings and annotated that the steel
plates and second layer of concrete blocks were “added
in June/July 1962.” Mr. Darr’s name and the date
annotation were omitted both in the SC&A review
drawing and in the GSI 1962 AEC license application
for the 0.5 Curie Co-60 sources.

Scientifically, this is a very troubling omission of
key data, because it confirms worker testimony (

) that no such steel plate shielding
was in use prior to 1962 when the same inner structure
was used with radium-226 sources and the “fishpole
technique” the AEC banned from use in the early 1960s
throughout the
USA. Workers state that 300 unbadged workers were near
the building 6 radiography facility. This differs from
the Allen-SC&A analysis.

Finding #2 indicates that neither NIOSH nor SC&A
thoroughly reviewed the McKeel NRC FOIA 2010-0012
materials. Lack of a door in the inner radiography
structure before 1962, and walls that were a single
concrete block thick, had been testified to NIOSH and
SC&A by GSI workers previously but was ignored in the
recent Allen white papers. Radium-226 doses in and
surrounding the building 6 radiography facility from
1953 to 1963 of the covered period should be
recalculated or modeled by NIOSH and SC&A. The SEC
issue is that no actual (that is real) radiologic
surveys had been made of this facility prior to 1962
when there was less steel and concrete shielding.
Again, the Darr June/July 1962 annotations proof the
changes were applied to an existing facility and
further confirm worker testimony to that effect.

_9-


radiography facility prior to 1962 when there was less steel and
concrete shielding. Again, the June/July 1962 annotations prove
the changes were applied to an existing facility and further confirm
worker testimony to that effect.

Another overall conclusion that applies to the three Findings is
that GSI license applications to the AEC cannot be trusted without
confirmation by readily obtainable worker testimony. This company was
clearly self-serving to the detriment of workers. The
June/July 1962 annotations should have been incorporated into the 1962
GSI cobalt-60 license application to the AEC, but apparently someone
removed them. This removal of key data casts doubt on the validity of
the entire Nuclear Consultants Corporation radiologic survey and input
to GSI’s 1962 AEC license application. Correct scientific data appears
to have been deliberately manipulated according to the written record.

GSI petitioners, site experts and former workers and claimants
ask that the TBD-6000 work group carefully consider these new findings
when making a final recommendation on GSI SEC-150 to the full Board.

We remain concerned about the inordinate amount of time it has
taken to revise GSI Appendix BB and for the work group to make its
initial recommendation on SEC-105.

Compare and contrast GSI with the two Brookhaven SECs. BNL had
multiple particle accelerators as did GSI and even had extensive film
badge data on all workers and had a known bioassay monitoring program.
GSI by contrast has minimal film badge data from one job category on
only 3% of workers, and zero bioassay data. The GSI SEC has been
considered for 3 years and four months since the NIOSH evaluation
report was issued without the TBD-6000 work group taking a formal vote
or making a firm recommendation.

There is a huge difference in processing times for both BNL SECs,
1 to 2 months with one being an 83.14 SEC, compared to the GSI SEC
time of 3 plus years and for Appendix BB to be revised 4 plus years.

The SEC and Appendix BB revision processes at GSI have dragged on
far too long to be considered at all reasonable. This lack of
timeliness at GSI is decidedly not claimant favorable by anyone’s


McKeel critique of David Allen and NIOSH January 2012 white paper

3. Issues that bear on validity and veracity of GSI dosimetry information:

Co-petitioner McKeel offered the following comments on both of the following issues to
the full ABRWH on February 28, 2012 at its regular meeting in Oakland, California.

G. Issue 8. The red steel roll up ribbon doors in the Old and New Betatron facilities
during the covered period. McKeel’s comments on 2/28/12 to the full Board were as follows

FINDING #1. The Betatron exit tunnel doors were NOT
double leaf and lead shielded during the covered
period of 1953-1966 as is stated in the January 2012
Betatron paper. We have photographic and affidavit
proof that the double leaf doors were installed in
1971 or 1972 after the covered period had ended.
Betatron workers to a man had always stated that the
tunnel exit doors on both the Old and New Betatron
buildings were a “steel red ribbon type roll up door.”

NIOSH evidence: On pages 2, 3 and 4 of the 30 page
January 2012 white paper Mr. Allen showed drawings of
the Betatron buildings from the 1992 FUSRAP cleanup
and the GSI cobalt AEC license renewal application.
The drawing had originated in the GSI 80 Curie AEC
license application in 1968, two years after the
covered period had ended. The text noted the doors
were “double leaf with lead shielding,” Similar
“double leaf doors” minus the reference to being lead
shielded were described and shown in drawings in the
ORNL DOE cleanup report for the GSI Betatron buildings
in 1992. The page 4 drawing indicates the nearest
building is 1000 feet away.

McKeel- _ evidence: There is both old and recent
direct worker confirmation that in the 1963-66 time
period the Old and New Betatron tunnel exits were
“red, steel, roll up ribbon doors” that could not be
retrofitted with lead shielding. - and McKeel
have their own Old and New Betatron photographs, and
ones from the Department of Energy cleanup in 1992
that they obtained, that indeed show the exit doors
have double leaf doors with vertical strips on the
lower panel. These doors bear no resemblance to the
red ribbon roll up door described by the workers at
the end of the covered period. However, in September
2006 Dan McKeel had a photograph of the exact type of
red, steel, roll up ribbon door that enclosed the
building 10 entry to the break area that was an
extension of the New Betatron Building tunnel. AEC
documents said the break area tunnel at the entry to
Building 10 was bounded by a chain mesh, Workers
testified that in 1963-66 the break area entry to
building 10 was wide open, not enclosed at all.

265


McKeel critique of David Allen and NIOSH January 2012 white paper

1974. However, the affected workers are and were both deceased and therefore were not
protected by the PA of 1974 at the time these requests for unredacted copies were made by the
petitioners. There is no polite term for this action by NIOSH: the best case scenario is that it is
censorship; the worst case scenario is that the denial of unredacted letters constitutes obstruction
of legal due process.

F. Issue #6: The petitioners challenge Dayid Allen’s use and job characterization of a
theoretical Layout man as the prototype for all workers at GSI apart from the Betatron
radiographers. In Allen’s construct in the January 2012 white paper, all workers other than
Betatron operators and assistant operators will be assigned one dose, and everyone else will be
assigned another dose calculated for the prototypical Layout worker. As a comment, confining
the Betatron operator dose only to people who worked most of the time in the Betatron buildings
is unfair, Why? Because many persons such as guards, electricians (prominently as workers have
testified), inspectors and certain other workers routinely entered and left the Betatron buildings
and could have accordingly received extra dose compared to a Layout worker who never entered
the Betatron facilities.

First, there is zero (no) film badge or urine uranium bioassay intake data or Radium-226
or cobalt-60 or industrial x-ray machine dosimetry monitoring data for any GSI workers except
the Betatron and isotope radiographers.

Second, there is no way to construct a valid co-worker model for GSI “general” workers
such as Layout workers because, as admitted first by OCAS Director Larry Elliott, “GSI is a
unique site.”

Third, there is no breakdown of Layout workers versus the general workforce at GSI with
tespect to gender. There is recent epidemiologic information form the general radiation literature
that for certain types of cancers women respond differently than men to radiation exposure
[REF], So, Layout worker may not be representative of the entire GSI workforce for gender.

Fourth, David Allen cites no evidence that GSI Layout workers actually received more
dose than GSI welders, burners and grinders, for example,

Fifth, Mr. Allen misrepresents what a Layout worker actually does. He ignores the fact,
established by petitioner and site expert photographs, that some steel castings required up to 400
(four hundred) separate shots. Allen's analysis indicates that almost all shots were either 15
minutes or 60 minutes.

Sixth, workers in building 10 near the break area and railroad tunnel entry to the New
Betatron building, and the 300 workers there is testimony worked near the inner roofless
building 6 radiography facility, probably received higher external doses compared to Layout
personnel in other parts of the factory, NIOSH cannot identify which particular workers were
the included in the “building 10” and the “building 6” GSI worker cohorts. This is an SEC issue
as well as a dose reconstruction issue.

Seventh and most importantly, the Allen analysis does not compare how the external
photon, neutron and beta doses calculated in the January 2012 white paper compare to dose
assigned to workers other than the Betatron operators in Appendix BB, Rev 0. This is a major
and crucial omission, since this white paper will form the basis for a revised Appendix BB Rev

| according to DCAS Director Stuart Hinnefeld. Such an analysis will be further important
guidance for health physicists Who will be charged with performing second (repeat) dose

reconstructions for GSI claims whose claims have been denied, It is certain that many such
situations will arise,


McKeel critique of David Allen and NIOSH January 2012 white paper

highest film badge doses have been deliberately and improperly withheld from the petitioners
and knowledgeable workers and site experts. The worker with the second highest film badge
dosimetry reading at GSI denies he was even informed about having received such a dose. If this
is a true statement, then how could that person have signed a letter addressed to Landauer
retracting his high film badge reading? We assert this did not happen. It is clear the true facts
from this episode have not been fully disclosed by NIOSH or by SC&A to the Board.

Such considerations engender a very disturbing reaction to the last two David Allen
white papers. This reviewer and long time GS] co-SEC-00150 co-petitioner has no choice but to
conclude that NIOSH is attempting to limit the dose to all GSI workers. | will leave assigning
motive to others. However, I must observe the overall effect is strongly adversarial to the true
intent of EEOICPA, and is definitely harmful to the financial well being of affected workers by
diminishing their chances to be fairly compensated based on scientifically sound, well

researched, and well described dose reconstruction methodology and practices.

Reference: Letter from Senator Barack Obama and Representative Henry A. Waxman to Stephen
L. Johnson Administrator, U.S. Environmental Protection Agency May 30, 2008. (URL:
http://www. ieer.org/sdafiles/16-1/referenceman-letters.pdf), The cited EPA letter states the
following: “At issue now is whether separate male and female risk coefficients should be
published for the general population, given the approximate two-fold difference in risk per unit
dose estimated in BEIR VII.”

Daniel W. McKeel, Jr. 2/27/2012

Appendix A and B attached

Respectfully submitted by:

Daniel W. McKeel, Jr., M.D.

GSI SEC-00105 co-petitioner

Founder: Southern Illinois Nuclear Workers (SINEW)
Retired Associate Professor of Pathology and Immunology
Washington University School of Medicine in St. Louis, MO
Phone: (573) 323-8897

Fax: (573) 323-0043

E-mail: danmckeel2@aol.com

US Mail: P.O. Box 15, Van Buren, MO 63965-0015

=J§-


McKeel critique of David Allen and NIOSH January 2012 white paper

the
Old Betatron Building railroad track exit on a site
visit photographed by Dan McKeel on 9-26-2006. It is
believed this type of door replaced the red roll up
steel doors in 1968 when GSI obtained its AEC license
for the 80 Curie Cobalt-60 source as an AEC licensing
requirement.



Appendix B: McKeel critique of Allen? January 2012 GSI white paper

Can you check with some of the other GSI Betatron workers and estimate the distance from The
"Old" Betatron Building to the
"New" Betatron Building ?

Please include the worker's names after you contact them,

Thanks,

Dan McKeel Comment 2/27/12: | agree completely that the drawing on page 4 of the Allen

DCAS/NIOSH January 2012 GSI Betatron Operations white paper shows that GSI misstated the
true facts about the distance to the nearest building to the New Betatron facility in their AEC
license application, which is the subject of NRC FOIA 2010-0012 that I first obtained, Such
misrepresentation by GSI reinforces the petitioner's position that GSI was in many instances
prone to deliver favorable but incorrect information to federal and state agencies that regulated
them. This inured to the detriment of former workers and their survivors who are now EEOICPA
claimants. Jn roro, these misrepresentations of facts by GSI, and their perpetuation by the current
federal agencies and deliberative bodies and governmental commissions that implement the Act,
converge to cause financial harm to GSI claimants in the form of denied compensation under
EEOICPA 2000 as amended. This is true whether or not the factual misrepresentations by GSI
and their perpetuation by others are “accidental” or intended, In addition, of course, the New

Betatron building was less than 100 feet away from the 10 building at GSI that housed many

never badged male and female GSI employees (burners, welders, chippers, etc.).

ji! ] }

right at GSI September 2006. Dan McKeel photo.

SF


Dragon, Karen E. (CDC/NIOSHIEID)

From: DanMcKeel2@aol.com

Sent: Monday, May 21, 2012 3:43 PM

To: NIOSH Docket Office (CDC)

Cc: danmckeel2@aol.com

Subject: Docket 140 GSI: PETITIONER DOCUMENT 1
Attachments: McKeel_GSlupdate_2.29.2012.pdf

Dear NIOSH Docket 140 Office:
Attachment: <McKeel_GS!_update_2.29.12,PDF> (4.2 MB)
Please accept this submission to GS! Docket 140 for posting on the DCAS website.

Description;

Critique, transition page, draft ABRWH McKeel Comment dated 2/28/12; E-mail dated 2/29/12 to Dr. Ziemer and Ted
Katz. Note the final McKee! Comment as presented to the Board during the Public Comment session is contained in the
transcript of the 2.28.12 ABRWH meeting on PAGES 280-292. The two versions differ significantly. Correspondence with
Mr, Katz related to this submission indicates the document was posted to NIOSH Docket 140 (GSI). HARD COPIES of
this document were given to all participants at the 3/15/12 TBD-6000 work group meeting in Cincinnati (Hebron, KY,
Airport Marriott).

Thank you,
Sincerely - Dan McKeel May 21, 2012

Daniel W. McKeel, Jr., MD
Phone: 573-323-8897
Fax: 573-323-0043

E-mail: danmckeel2@aol.com
US Mail: P.O. Box 15, Van Buren, MO 63965-0015


McKeel critique of David Allen and NIOSH January 2012 white paper

The NRC FOIA 2010-0012 material from which the above drawing was taken was
available to both NIOSH (David Allen) and to SC&A (Robert Anigstein) when their respective
reports were written in 2010 and 2012. They should have been aware of this drawing.

This new understanding of the different physical characteristics and shielding in the
building 6 Radiography structure pre- and post June and July 1962 and the AEC license
application radiologic survey of August 1, 1962 by Nuclear Consultants Corporation has another
important implication, SC&A reported MCNP modeling of radium-226 when part of this work
was done inside the building 6 Radiography facility and part was done in the rest of the GSI

building complex (see and interviews) as follows:

Effective Date:
10/20/2011 Revision No. 0 — Draft Document Description: White Paper:

Update on the Use of Sealed Radioactive Sources at GSI Page No. Page
19 of 25

Appendix B MCNP SIMULATIONS OF EXPOSURES FROM 226RA
IN NO. 6 BUILDING

Prepared by Robert Anigstein and Richard Olsher S. Cohen & Associates

* We simulated the exposures and dose rates from 226Ra in the

radiographic facility in No. 6 Building at GSI using the MCNPS radiation

transport code. The model of the radiographic room was based on a

sketch in the GSI application for an AEC byproduct material license (NRC

2009¢, p. 31), which is replicated in Figure 4.

However, all or essentially all of the radium-226 NDT work at GSI was done pre-1962
when, we now know through D. Darr’s annotation, all of the shielding, the steel plates and added
concrete block wall thickness, allegedly was added to the building 6 radiography structure in
June and July 1962. So SC&A incorrectly modeled the better shielded post July 1962 situation
rather than the correct situation that prevailed after mid-1962, The petitioners therefore assert
that all radium-226 modeling reported by SC&A is thus substantially incorrect, and to
preserve claimant favorability the SC&A analysis should be retracted and redone to reflect the
higher doses the radium-226 fishpole technique operators would have undoubtedly been
subjected to before July 1962 of the covered period when the radium-226 NDT work was
actually performed, NIOSH needs to address the lack of observational evidence that the stee!
plate shields were actually in place at a specific date.

I must reiterate the fact that an extra thickness of concrete blocks was added in June and

July 1962 has been challenged by a GSI worker (JTD), who told the petitioner he climbed up to


MeKeel critique of David Allen and NIOSH January 2012 white paper

Another overall conclusion that applies to both
Findings is that GSI license applications to the AEC
cannot be trusted without confirmation by readily
obtainable worker testimony. This company was clearly
self serving to the detriment of workers, It is clear
to us that GSI. The D. Darr June/July 1962 annotations
should have been incorporated into the 1962 GSI
cobalt-60 license application to the AEC, but
apparently someone removed them. This removal of key
data casts doubt on the validity of the entire Wilfred
Konneker and Nuclear Consultants Corporation
radiologic survey and input to the GSI license
application, Correct scientific data appears to have
been deliberately manipulated according to the written
record,

GSI petitioners, site experts and former workers
and claimants that the TBD-6000 work group carefully
consider these new findings when making a final
recommendation on GSI SEC-00150 to the full Board.

te OF THR
PacaRabeic. Facierty

Senekey Sreet Tetusreies
kant, Cory. See

te Comthere Bice baie
a

16% Coueer
feote
wan

4 . Siew ais S35. Bae
“erm eres
ARFA , » * LY

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Swows AD_ITIONAL SHIELDING
Appeo DueinG Tuse- Tay Mer,
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. D.Daee
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Legend added; D. Darr signature clear with annotation
“Shows Additional Shielding Added During June-July 1962."

-10-


estimate. We again urge the TBD-6000 work group and full Board to

approve the GSI SEC-105 at its next Board meeting. If BNL deserves its
SECs, then clearly GSI does too.
Thank you.

Footnote

Copy e-mailed to Dr, Paul Ziemer 2/29/2012 at his request. This was
the sole Public Comment at the Oakland, CA ABRWH meeting on 2/28/12.
--DWM Jr



McKeel critique of David Allen and NIOSH January 2012 white paper

These observations lead to several important
conclusions:

Conclusion 1) It is incorrect to reconstruct doses
for the covered period based on the assumption there
was a double leaf lead shielded door to stop limit the
dose to workers in building 10 and in the New Betatron
break area. This section of the second Allen white
paper should be retracted and doses redone based on a
roll up unshielded steel door at the end of the two
Betatron tunnels.

Qonclusion 2) The January 2012 Allen white paper
also contains the incorrect statement that the nearest
building from the Old Betatron building during the
covered period was 1000 feet away. In fact, to the
contrary, the Old and New Betatron buildings were only
300 feet apart. The outside of the Old Betatron
Building contained a sign, that McKeel photographed in
2006, which said “Do Not Approach This Building within
100 Feet.” We hold this sign meant that radiologic
surveys must have established a significant radiation
danger field around the Old Betatron building. We can
assume a similar danger zone also surrounded the New
Betatron facility. Those 100 foot radius zones would
clearly involve persons in building 10 and in the
space between the two Betatron buildings. This was a
very busy area that many unbadged workers also used to
by-pass walking through the foundry, Casting “flasks”
filled the area that had to be placed there. Many
persons parked within 100 feet of the New Betatron
facility as proven by photographs from the GSI
magazine. These between Betatron doses have not been
modeled or measured accurately by NIOSH, nor have they
been recognized or modeled by SC&A.

€onclusion 3. Once again NIOSH and SC&A have given
insufficient weight to worker testimony about the true
mature of the Betatron doors and shielding in the
covered period. Instead, the paper uses information
about the Betatron facilities from the residual period
that has no relevance to the covered period situation.

On the next page are photographs of the double leaf doors placed, the petitioners and site
experts believe, in 1968, after the covered period which ended in 1966. Lead shielding was not
observed by any living Betatron workers on the double leaf doors at the Betatron exit tunnels.
The doors that should have been modeled in the Allen January 2012 white paper are also shown
on the next page as “red, steel, roll up type ribbon doors” that all GSI workers agree closed off
the rail track tunnels to the two Betatron facilities during the covered period. The building 10
door shown blocked the entry to the New Betatron tunnel in 2006, a place the workers say was

open during the covered period, and DOE 1992 cleanup documents say had a wire mesh closure.

fe


Appendix A: McKeel critique of Allen2 January 2012 GSI white paper

July 1, 1961 to June 30, 1962 437.5 hrs/yr (based on a total limit of $7000) No Badges, 437.5 hes/yr
July 1, 1962 to June 30, 1963 125 brs/yr (based on a total limit of $2000) No Badges 125 brs/yr
July 1, 1963 to June 30, 1965 28 hrs/vr (based on a total limit of $450) NLOSH using this
information. 28 hrs/vr

duly 1, 1965 to June 30, 1966 13 hrs/vr (based on a rotal limit of $450 at $35/hr) (Note: Uranium was

only at GSI until June 30, 66)
NIOSH using this information, 13 hrs/vr

raying uranium". These are considered maximum because the purchase orders set these

costs as a limit. There is no indication how much of the available funds were actually used. Also the cost was to include
maintenance down time and overhead as well as the

cost of film.
Dan McKee! comment 2/27/12 -- This exchange shows that NIOSH DCAS/OCAS at two

junctures, under two different Directors, deliberately distorted their own data to establish the
false “fact” that 1964-66 were the peak years for MCW-AEC contracted uranium NDT work at
the GSI AWE site. David Allen repeats and compounds this same misinformation in his January
2012 white paper on Betatron operations that will form the basis for REV | of Appendix BB.

By the end of 1966 compared to 1961, uranium radiographic NDT activities had declined from
437,5 hrs in 1961 to just 13 hours in 1966, a whopping 97%! This is an example of NIOSH data
manipulation being used to the severe detriment of GSI claimants. From these data, the GST
petitioner's long held view that 1964-66 are non-representative of the covered period from 1953-
1966 for MCW-AEC uranium operations is even more firmly established.


and McKeel photographs, and ones from the Department of
Energy cleanup in 1992, show the tunnel exit doors have double leaf
doors with vertical strips on the lower panel. There is no lead
shielding. These doors bear no resemblance to the red ribbon roll up
doors described by the workers for the GSI covered period. In
September 2006 Dan McKeel photographed the exact type of red, steel,
roll up ribbon door that now enclosed the building 10 entry to the New
Betatron Building break area and rail track tunnel. AEC documents said
the break area tunnel at the entry to Building 10 was bounded by a
“chain mesh.” Workers testified that in 1963-66 the break area entry
to building 10 and the New Betatron was wide open, not enclosed at
all,

These observations lead to several important conclusions:

First, it is incorrect to reconstruct doses for the covered
period based on the assumption there was a double leaf lead shielded
door to limit the dose to workers in building 10 and in the New
Betatron break area. This section of the second Allen white paper
should be retracted and doses redone based on a roll up unshielded
steel door at the end of the two Betatron tunnels.

Second, once again NIOSH and SC&A have given insufficient weight
to worker testimony about the true nature of the Betatron doors and
shielding in the covered period. Instead, the paper uses information
about the Betatron facilities from the residual period that has no

relevance to the covered period situation.

Finding 2. The January 2012 Allen white paper also perpetuates
the incorrect statement that the nearest building to the New Betatron
building during the covered period was 1000 feet away. In fact, to the
contrary, the Old and New Betatron buildings were only 300 feet apart.
The outside of the Old Betatron Building contained a sign, that McKeel
photographed in 2006, which said “Do Not Approach This Building Within
100 Feet.” We hold this sign meant that a significant radiation danger
field existed around the Old Betatron building. We can assume a
similar danger zone also surrounded the New Betatron facility. Those

100 foot radius zones would clearly involve persons in building 10 and

= 3 =


McKeel critique of David Allen and NIOSH January 2012 white paper

materials DOE plant operations at the Weldon Spring Feed Materials Plant in St. Charles
County].

[1] The GST petitioners and site experts have produced unchallengeable data from
Mallinckrodt documents that David Allen’s analysis of GSI nondestructive testing of
Mallinckrodt uranium during 1953-66 is incorrect in at least three aspects:

[la] MCW and Weldon Spring sent 2-step uranium ingots and |-step uranium
dingots to GSI for nondestructive radiographic testing (“X-ray NDT”) using the two plant
Betatrons. These uranium forms were in addition to the uranium slices that David Allen rerred to
in the January 2012 white paper.

[1b] The purpose of X-ray NDT at GSI on Mallinckrodt uranium was not only, or
even primarily, to uncover structural defects as David Allen claims in the January 2012 white
paper. Rather, the major purpose was ta define the interface between the outer magnesium
“slag” or “crust” that coated each ingot or dingot after it emerged from the “bomb” (metal
vessel) in which the ingot or dingot was formed. MCW needed this precise slag/pure uranium
interface location information in order to guide the lathes that shaved away the mg-fluoride crust
to expose the pure uranium surface of the ingot or dingot. The petitioners and Mr. “ave
described and documented this process by documents and photographs. It is really unfathomable
why this basic fact is ignored repeatedly by NIOSH and Mr. Allen. Obviously, an entire intact
ingot or dingot would have to be examined by x-ray NDT at GSI. The goal could be, and we
contend was, reached by doing glancing shots around the ingot/dingot. The crust was only a few
inches thick, and the underlying interface with the pure uranium was readily imaged by the
powerful Betatron x-ray beam. GSI Betatron operator clearly described this process
on the record.

[1c] The heavy uranium ingots, dingots (and possibly the “Betatron slices”) were
transported from Mallinckrodt-Destrehan Street or Weldon Spring Feed Materials Plant to GSI
across the Mississippi by truck. Those trucks had to be unloaded when they reached GSI. Heavy
stee] castings and the uranium, according to worker testimony, were transported within the GST
campus and building complex by rail. Railroad engines were used to bring the castings and
uranium into the Old Betatron Building. Petitioners and Mr. have provided maps of the
route of these GSI railroad tracks, Railroad tracks entered both Betatron facilities. There were no
docks for trucks in either Betatron building. Castings and the uranium ingots and dingots, each
weighing perhaps 3,000 pounds, were transported through several GSI buildings and through
building 10 by electric rail engine on the way to the tunnel entry to the New Betatron facility that
adjoined and was connected to Building 10. NIOSH has failed to calculate exposures to the many
unbadged workers who handled the uranium during the transport loading and unloading and
transport operations described above. These real doses have to be calculated and be made part of
the assigned external and internal dose for uranium by unbadged and badged workers, This has
not yet been done despite repeated urging by the petitioners, site experts and workers to do so,

(Id) David Allen in the January 2012 white paper incorrectly states several facts
to support his rationale for using the New Betatron doses, based on film badge readings of the
operators, as bounding for the Old Betatron x-ray unit for the entire covered period of 1953-
1966. This is not just a dose reconstruction issue; it is also a fundamental SEC issue. Mr. Allen is
incorrect in stating that the peak uranium volume for Betatron NDT examinations was during the
last three years (1964-1966) of the GSI covered period when film badge data were available, In
fact, as has been documented on the record previously by analyzing MCW-AEC purchase orders
issued to GSI, the peak year was 1962. Thereafter, uranium shipments took a sharp decline in

3 tt


MeKeel critique of David Allen and NIOSH January 2012 white paper

Simply turning the Betatron 45 degrees to the right, to radiograph the end

of the casting, does not require any “flipping”.

It would also send the Betatron beam “right down the tracks" towards the doors.
This was a common “timesaving” proceedure per numerous workers, including

T.Dutko/ GSI operator.

i ZONC ‘S:
I decided not to submit a line-by-line rebuttal to the David Allen and NIOSH January
2012 white paper because the “big picture” extensive factual and scientific distortions,
intentional selective citation, lack of proper professional attribution, and inaccuracies assumed
overarching importance when I reviewed this second white paper in an Appendix BB process

that has now dragged on since October 2010 (16 months). This report does a disservice to the

-14-


McKeel critique of David Allen and NIOSH January 2012 white paper

previous by SC&A using MCNP and NIOSH using Auila. Why NIOSH switched computer
modeling code is not justified in Allen January 2101, Dr, Anigstein from SC&A has commented
that different software versions of MCNP give different results. Mr. Allen again overlooks these
important scientific points. It appears that Mr. Allen is assigning Betatron workers an overall
dose that is approximately 75% of the dose SC&A assigned to them previously based on SCRA
MCNP modeling results. These lower doses assigned to Betatron workers in part may reflect the
incorrect assumptions that lead shielded doors covered the Betatron shooting area exits. We have
shown these assumptions were false.

7. Both NIOSH/DCAS in Allen January 2012 and SC&A (in their review of Allen
October 2010) used drawings from the GSI 1962 cobalt-60 license application to AEC that were
altered in significant ways compared to the original drawings from two months earlier where “D.
Darr” annotated the steel plate shields and the double concrete walls were added only | to 2
months earlier in June and July 1962. There is meager evidence that the steel radiation shields
were added, One former worker says yes and another says no. There is no support for the
proposition, that is no worker affidavit confirmation, that a second layer of concrete blocks was
ever added to the walls on the inner Radiography structure to Building 6.

8. Related to point #6, NIOSH needs to calculate separate doses for radiographers using
the radium-226 sources with the fishpole technique before 1962 (when no shielding was in pace,
a single block wall existed and possibly there was no door) and after 1962 to 1966. Workers
testified that both Ra-226 and 0,5 Curie cobalt-60 sources were used for a short while during
1962 and then the ra-226 sources were abandoned as mandated by the AEC for safety reasons.
Mr. Allen fails to acknowledge these nuanced points, nor have the necessary dose calculations
been carried out.

9. A former GSI Betatron operator who was very familiar with the two Betatron facility
control rooms disputes there Was a separate “control room badge” as Allen reports the Landauer
film badge data indicates. This person (JTD) is well known to the Board and is willing to sign an
affidavit to that effect. The petitioners believe and assert the contro! room badge data cannot
therefore be validated or trusted, and that the 114 readings do not necessarily represent the true
dosimetry readings in the two control rooms. SC&A modeling, in fact. showed the highest levels
of radiation occurred in the control room that was supposed to be protecting the workers. The

Betatron control rooms both had thin metal doors that would not impede the high Mev photons

été


MeKeel critique of David Allen and NIOSH January 2012 white paper

e.3) Co-petitioner Dan McKeel and site expert _ together
interviewed Jack Scheutz, an NIOSH contractee, more extensively person-to-person and before
NIOSH interviewed Mr. Scheutz, NIOSH has been informed by co-petitioner McKeel that Mr.
Scheutz said that Allis-Chalmers, for whom he worked and which was the company that installed
the GSI Old Betatron, “always” conducted a complete and comprehensive radiation dosimetry
of all Betatrons facilities they installed. Mr. Scheutz also told McKeel and - _ _ hathe
“destroyed those building surveys when he took over the assets of Allis-Chalmers Betatron
operations and began his service business." However, to our knowledge, NIOSH and DCAS
have made no effort to secure possible copies of these radiation surveys that would, of course, be
immensely relevant to Betatron operations at GSI and other EEOICPA sites such as Allis-
Chalmers itself and Los Alamos that also operated A-C manufactured Betatrons during the
covered period. McKeel challenges the credentials of Mr. to be the most definitive
source of data on GSI operations, He was not a physicist, nor was he credentialed as a health
physicist, He was a well trained Allis-Chalmers Betatron technical repair person to our
knowledge. Also, it was clear to McKeel during the direct interview that Mr. had a
vested interest in promoting Betatron technology as a safe NDT modality, Therefore his
viewpoint is biased in this way, and this fact needs to be acknowledged in assigning a weight to
Mr. testimony.

2. Specific dose reconstruction and SEC issues;

A. Issue #1: Exposure data from an 80 Curie cobalt-60 source from the 1968-71 during
the residual contamination period cannot be used to model Betatron exposures during the
1953-1966 covered period. This entire section and analysis should therefore be completely
disregarded and not allowed to be part of a revised Appendix BB, the announced intention of
producing this new technical paper. There is no surviving GSI Betatron x-ray dosimetry data. All
of the logbooks, “shot records,” x-ray check off and analytic reports known to be generated for
the MCW Uranium Division by GSI, uranium ingot shipping manifests and inventory sheets,
have been lost, destroyed or misplaced (and therefore not found) by DOE/NARA. The
petitioners have repeatedly suggested that NIOSH seek these records among MCW reports, yet
this data capture effort has never been made by ORAU as part of the EEOICPA funded Data
Capture program to our knowledge.

B. Issue #2: External and internal photon doses, beta skin doses, and neutron data
derived from calculated 1963-66 photon-to-neutron ratios cannot reliably be back
extrapolated from the 1953-66 early years of the GSI covered period. These p-to-n rations
were based on modeled photon doses rather than real doses. There is no actual (measured)
neutron data from the two GSI Betatrons. Other SECs such as the first Rocky Flats SEC were
approved because p-to-n partial dosimetry data was not thought to be sufficiently accurate to
define dose. Ther eis no convincing NIOSH neutron data at GSI, even though it has been shown
by the petitioners that the ~15% of the output beam of 24-25 Mev Allis-Chalmers Betatrons of
the same type as used at GSI was neutrons.

jo Issue #3: NIOSH and Dayid Allen have mischaracterized the uranium source term

at GSI in at least 4 important ways: [Note; The term “Mallinckrodt” refers to the Uranium
Division of Mallinckrodt Chemical Works-Destrehan Street and the Uranium Division feed

Py 5-4


Transition Page Between
CRITIQUE and PUBLIC COMMENT
by Daniel W. McKeel, Jr.

February 29, 2012

« The single spaced indented text on pages 6 and 7, section G, Issue 8, Finding #1
of the Critique, and the text on pages 9 and 10, section H, Issue 9, Finding #2
were part of a draft public comment by Dan McKeel to the ABRWH on 2/28/12.
The text contained omissions, typographic mistakes, and grammatical errors that
were corrected prior to the final version that follows.

* Before the Public Comment was delivered to the Board, the text was slightly
modified and rearranged to include 3 Findings and a section regarding a
comparison between the way the TBD-6000 working group and Board processed
GSI Appendix BB to TBD-6000 and SEC-00105 and the way the Board
processed two SECs, one 83.13 and one 83.14 petitions for Brookhaven National
Laboratory (BNL).

* The text on the last 5 pages is the McKeel Public Comment that was actually
delivered over the phone to the Board by phone at approximately 5:15 PM to 5:25
PM Pacific Time. This version closely adheres to the text that will appear as part
of the official ABRWH meeting transcript of February 28, 2012.


MeKeel critique of David Allen and NIOSH January 2012 white paper

Daniel W. McKeel, Jr., M.D.
Critique of the NIOSH January 2012 White Paper
“Dose Estimates For Betatron Operations,” David Allen DCAS Author

1 General comments on GSI dose reconstruction:

a) The October 2011 and January 2012 Allen white papers about GSI portable and
Betatron sources need to be acknowledged as being the basis for a revised Appendix BB to the
parent Battelle TBD-6000 document. This may be inferred but is not stated explicitly.

b) It should also be acknowledged by NIOSH that the Director of DCAS has stated
unequivocally that these two white papers are not the basis for a revised SEC-00105 evaluation
report. DCAS Director Stuart Hinnefeld has written to the GSI petitioners and has stated
unequivocally that “NIOSH has no plans to revise its evaluation report of SEC-00105.”

c) There is zero urine uranium bioassay monitoring data for any GSI worker for the
covered period of 1953-1966, GSI has repeatedly minimized, we believe incorrectly, the intake
dose potential inside the two GSI Betatron facilities.

d) The new Betatron modeling dosimetry results using the MCNP code in the January
2012 Allen white paper are misleading in that there is no direct comparison with earlier dose
modeling by SC&A using MCNPx code and by NIOSH using Attila code. The early results
disclosed a highly significant, scientifically troubling order of magnitude or greater discrepancy
between the computer models and the limited GSI film badge results. In addition, the NIOSH
and SC&A models disclosed significant differences between them. These early results need to be
reconciled with the new results. How do the NIOSH MCNP results compare to the earlier Attila
code results by NIOSH? Why were the analyses switched from Attila to MCNP?

e) Mr, Allen and NIOSH have been repeatedly non-transparent about how certain of
their key dosimetry data came into their possession.

e,1) In particular, co-peritioner McKeel first discovered the presence of Landauer
GSI film badge data to NIOSH 13 months before NIOSH obtained the complete data set. McKeel
made the initial contact that led to this important revelation. This was acknowledged in part by
Mr. Allen in an open meeting in Collinsville, IL in 2006. However, the fact has not been
acknowledged in NIOSH technical reports, including the January 2012 paper being critiqued
here.

e.2) Also, co-petitioner Dan McKeel, not NIOSH, filed the FOIA request that led
to the release of NRC FOIA 2010-0012 documents on the NRC website. When McKeel provided
these data to NIOSH a few weeks after obtaining 1,016 pages of GSI by-product materials
licensing information, he explicitly provided the following language as to how these documents
should be attributed. This reasonable request has been totally ignored by NIOSH. Co-petitioner
McKeel believes NRC decided to release these documents because McKeel provided them with
a compelling set of answers to eight questions that must be answered to have NRC waiver fee
waivers. As a result, McKeel believes, NRC released the 1,016 pages—unredacted —without
charging him a fee. In addition, NRC voluntarily provided McKeel an unredacted Index of all
these FOIA documents, listing 37 different sets of documents that comprised the whole. McKeel
provided this Index to NIOSH, where it was and is posted in a heavily redacted form. NIOSH
has never provided a valid explanation why they heavily redacted the unredacted NRC Index
given to McKeel and posted later on the NRC website, including names of many deceased
persons that are not subject to protection by the Privacy Act of 1974.

HB


in the space between the two Betatron buildings. This was a very busy
area that many unbadged workers also used to by-pass walking through
the foundry. These between-the-building Betatron doses have not been
modeled or measured accurately by NIOSH, nor have they been recognized

or modeled by SC&A.

Finding #3. The building 6 radiography facility at GSI has been
incorrectly modeled for the period 1953-1962 when Radium-226 was being
used for nondestructive testing, This is an SEC issue. The October
2011 Allen white paper on GSI portable sources shows an August 1962
drawing of the building 6 roofless radiography facility. SC&A uses the
same drawing in their review. Packet 5 of 37 of the NRC FOIA 2010-0012
material shows the same drawing in which ” " has signed the
drawings and annotated that the steel plates and second layer of
concrete blocks were “added in June/July 1962.” Mr name and
the date annotation were omitted both in the SC&A review drawing and
in the GSI 1962 and subsequent AEC license application for the 0.5
Curie Co-60 sources.

Scientifically, this is a very troubling omission of key data,
because it confirms worker testimony that no such steel plate
shielding was in use prior to 1962 when the same facility was used
with radium-226 sources and the "fishpole technique.” The AEC banned
Ra-226 and the fishpole NDT technique from use in the early 1960s
throughout the USA for safety reasons. Workers state that 300 unbadged
workers labored near the building 6 radiography facility. This differs
from the Allen-SC&A analysis.

Pinding #3 indicates that neither NIOSH nor SC&A thoroughly
reviewed the McKeel NRC FOIA 2010-0012 materials. Lack of a door in
the inner radiography structure before 1962, and walls that were a
single concrete block thick, had been revealed to NIOSH and SC&A by
GSI workers previously but was ignored in the recent Allen white
papers. Radium-226 doses in and surrounding the building 6 radiography
facility from 1953 to 1963 of the covered period should be
recalculated or modeled by NIOSH and SC&A. The SEC issue is that no

actual (that is real) radiologic surveys had been made of this

~2«



MeKeel critique of David Allen and NIOSH January 2012 white paper

the top of the building 6 radiography wall in 1963 and observed the wall was “only one block
thick.” NIOSH needs to produce observational data to confirm that extra concrete was actually

added to make the walls 24 inches thick in the building 6 Radiographic facility.

i Issue #10. The peak period for uranium NDT work at GSI was not 1964-66 (detailed
information in Appendix A). Related to D Issue #4 on page 4, the January 2012 GSI white paper
perpetuates another error first promulgated by the former OCAS Director Larry J. Elliott. That is,
that the peak uranium radiographic NDT operations on MCW-AEC uranium took place during
1964-66 when film badge data is available on 89 Betatron and isotope radiographers. In fact, as
shown from Rev 0 of Appendix BB, section 2.2, there was a dramatic decline in MCW uranium

purchase orders to GSI for uranium NDT work from 1961 to 1966 amounting to 97 percent!

J. Issue #1]. The nearest distance to another building from the Betatrons was not 1000
feet (support information in Appendix B) as was claimed in the 1962 GST AEC license
application to obtain cobalt-60 sources. Mr. and several GSI Betatron operators
refute the erroneous statement on the GSI 1962 cobalt license examination that the nearest
building was 1000 feet away from the Betatrons, That is decidedly not true. Measurements by

shown in Appendix B, estimates by GSI workers, and SC&A data all indicate the
two Betatron facilities were within 300 to 312 feet of one another. The inter-building area bore
heavy human traffic as has been mentioned.

As [have noted, the Old Betutron Building contained a sign that read “Do nol approach
within 100 feet of this building.” Dan McKeel photographed this faded sign in 2006 and it was
shown to be present in 1992 photographs of the same facility that obtained from
DOE made during the cleanup campaign.

GSI should not have made this false statement to the AEC, and Mr. Allen should have

disavowed the factual basis for the assertion in his January 2012 white paper,

K. Issue #12. David Allen incorrectly describes “head flipping” of the Betatron. The
following entry occurs on page 7 of 30 of the January 2012 David Allen GSI white paper:


McKeel critique of David Allen and NIOSH January 2012 white paper

EEOICPA process and is the opposite to the intent of Congress to be claimant favorable in every
way when our elected federal officials established EEOICPA in 2000 to compensate deserving
nuclear weapons workers. This report even being allowed to take a further 15 months to research
and be published is an affront to every GSI claimant and to the petitioners, and to GSI advocates
and experts, and supporters and families of GSI workers and claimants. It is a further affront that
Appendix BB has not been revised since June 2007 when Rev 0 was released.

This summary and conclusions includes information from the October 2010 Allen white
paper that dealt with portable radiation sources at GSI, The two Allen white papers encompasee
all ten new dose reconstruction “models” that were originally outlined by Mr. Hinneteld in his
initial announcement that NIOSH would undertake these new studies.

My concluding points can be summarized in brief statements as follows:

1. NIOSH has failed to fully comply with its own guidance OCAS-IG-003 that for dose
reconstruction purposes all radiation sources at a facility during the covered period must be
calculated with sufficient accuracy,

2. NIOSH in the January 2012 Allen white paper improperly cites cobalt-60 dosimetry
obtained outside of the covered period to characterize Betatron worker doses during the covered
period. In the October 2010 Allen white paper on portable GSI sources, NIOSH challenged and
denied that an 80 Curie cobalt-60 source was in use at GSI before 1968. The covered period
ended in 1966, NIOSH cannot have it both ways.

3, Further, with respect to point #2, the radiation characteristics (energy spectrum,
directional vectors, neutron content, and extent of the radiation fields) differ completely from
that of the Betatrons,

4. The radiation patterns cannot be assumed to be comparable or lower for the Old
compared to the New Betatron buildings as David Allen does in the January 2012 white paper.

5, The two most recent Allen white papers fail to cross correlate the new doses
calculated for Betatron workers and layout (rest of the GSI work force) workers with the two
dose levels assigned to Betatron and other workers in Appendix BB. The methods and computer
codes were quite different, This will be key for calculating doses in reopened denied cases (so
called “reworks”).

6. In the January 2012 second Allen white paper there is no cross comparison between
the new NIOSH dosimetry calculations for the Betatron using MCNP and the doses modeled

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